The SRB will monitor regulatory changes related to competent authorities’ discretion to temporarily exclude certain exposures to central banks from the calculation of an institution’s total exposure measure (i.e. leverage amount), as granted by the Regulation (EU) 575/2013[1] (“CRR”). In September 2020 the ECB used this temporary measure to facilitate the implementation of its monetary policy during the Covid-19 pandemic[2]. As announced by the ECB, banks may benefit from the relief measure until the end of March 2022.
The leverage ratio requirement and the leverage amount can influence the calibration of the final MREL[3] targets as well as the compliance with the requirements at 1 January 2024.
Therefore, the SRB will monitor the regulatory changes – whether competent authorities will deem it necessary to extend or not the measure beyond March 2022 – and their impact in the computation methodology of the leverage amount that might lead to consequences for the final MREL targets.
If needed, the SRB will take corrective actions in the annual MREL setting by re-calibrating the final targets on the basis of changed leverage amounts and requirements. In practice, this means that if the relief is not extended, the SRB will re-calibrate MREL targets based on the leverage amount including central bank exposures. The monitoring of compliance with the build-up towards the final MREL targets will also take this into account.
[1] Article 429a of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and amending Regulation (EU) No 648/2012.
[2] Decision (EU) 2020/1306 of the European Central Bank of 16 September 2020 on the temporary exclusion of certain exposures to central banks from the total exposure measure in view of the COVID-19 pandemic (ECB/2020/44) and Decision (EU) 2021/1074 of the European Central Bank of 18 June 2021 on the temporary exclusion of certain exposures to central banks from the total exposure measure in view of the COVID-19 pandemic and repealing Decision (EU) 2020/1306 (ECB/2021/27).
[3] Minimum Requirements for Own Funds and Eligible Liabilities.
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